Medicare Part D: Fundamentals, Updates, and Operationalizing the Coverage Gap Discount Program

April 30, 2014 9:00am

Melissa K. Bianchi
Hogan Lovells US LLP

• ​Understanding the mechanics of how Part D is run
– What subsidies and payments do Part D plans receive?
– Interaction with 28% Retiree Drug Subsidy and commercial rebates
• Reporting of Part D rebates and PBM administrative fees
• Part D fraud & abuse issues
• Identifying critical dates for Part D participation
• Rebate contracting strategies under Part D
• Assessing new opportunities and pitfalls from the closing of the Coverage Gap over time
• Preparing for potential new mandates imposed by the Independent Payment Advisory Board
• Taking advantage of revolutionary changes from plan star ratings
• Potential legislative changes to require Medicaid-level rebates in Part D
• Overview of PPACA legislation and CMS program design
• Validating TPA CGDP invoice amounts
• Managing the logistics of payments to multiple plan sponsors
• CGDP payment disputes
• Conduct of CGDP audits
• Restrictions on use of CGDP data
• What are manufacturers’ appeal rights?
• Interaction with “Outside of Medicare” Part D patient assistance programs
• Quarter-by-quarter analysis of managing accruals for the coverage gap
– Surprises
– Lessons learned